for the northern district of texas dallas division ralph s

RECEIVER’S ORIGINAL COMPLAINTAGAINST POLITICAL COMMITTEES 1

IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

RALPH S. JANVEY, IN HIS CAPACITY AS COURT-APPOINTED RECEIVER FOR THE STANFORD INTERNATIONAL BANK, LTD., ET AL.,

Plaintiff,

v.

DEMOCRATIC SENATORIAL CAMPAIGN COMMITTEE, INC.; NATIONAL REPUBLICAN CONGRESSIONAL COMMITTEE; DEMOCRATIC CONGRESSIONAL CAMPAIGN COMMITTEE, INC.; REPUBLICAN NATIONAL COMMITTEE; and NATIONAL REPUBLICAN SENATORIAL COMMITTEE,

Defendants.

§§§§§§§§§§§§§§§§§§

Case No. _____________

________________________________________________________________________

RECEIVER’S ORIGINAL COMPLAINT AGAINST POLITICAL COMMITTEES________________________________________________________________________

SUMMARY

1. The Court has ordered Receiver Ralph S. Janvey (“Receiver”) to take control of

all assets of the Receivership Estate in order to make an equitable distribution to claimants

injured by a massive fraud orchestrated by Allen Stanford, James Davis, and others.

2. The Receiver’s investigation to date reveals that revenue from the sale of

fraudulent certificates of deposit generated substantially all of the income for the Stanford

Defendants, including Allen Stanford (“Stanford”) and James Davis (“Davis”), the Stanford

Financial Group, and the many related Stanford entities.

3. Allen Stanford, James Davis, and the Stanford Financial Group contributed more

than $1.8 million of their ill-gotten gains to a variety of political organizations and candidates.

Case 3:10-cv-00346-F Document 1 Filed 02/19/2010 of 14

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Text Box

3:10-cv-346


The defendants in this case, the Democratic Senatorial Campaign Committee, Inc.; the National

Republican Congressional Committee; the Democratic Congressional Campaign Committee,

Inc.; the Republican National Committee; and the National Republican Senatorial Committee

(collectively, the “Committee Defendants”), received more than $1.6 million in funds ultimately

traceable to money investors paid to the Stanford Defendants for the purchase of fraudulent

CDs.

4. The Committee Defendants did not furnish any consideration whatsoever for the

funds they received from Stanford, Davis, and the Stanford Financial Group. Consequently, they

have no legitimate right to retain the funds, and the Receiver is entitled to the return of all such

funds.

5. The Receiver has made written requests to the Committee Defendants for return

of these funds, first in February 2009, and again in February 2010. The Committee Defendants,

however, have ignored these requests, and, as a result, the Receiver has been forced to file this

lawsuit seeking the return of the funds to the Receivership Estate for the benefit of claimants.

6. The Receiver seeks an order that: (a) the payments from Stanford, Davis, and the

Stanford Financial Group to the Committee Defendants constitute fraudulent transfers under

applicable law; (b) the payments from Stanford, Davis, and the Stanford Financial Group to the

Committee Defendants are property of the Receivership Estate held pursuant to a constructive

trust for the benefit of the Receivership Estate; (c) the Committee Defendants are liable to the

Receivership Estate for an amount equaling the payments they received from Stanford, Davis,

and the Stanford Financial Group; and (d) the Receiver is entitled to an award of reasonable

attorneys’ fees, costs, and interest.



JURISDICTION & VENUE

7. This Court has jurisdiction over this action, and venue is proper, under Section

22(a) of the Securities Act (15 U.S.C. § 77v(a)), Section 27 of the Exchange Act (15 U.S.C.

§ 78aa), and under Chapter 49 of Title 28, Judiciary and Judicial Procedure (28 U.S.C. § 754).

8. Further, as the Court that appointed the Receiver, this Court has jurisdiction over

any claim brought by the Receiver to execute his Receivership duties.

9. Further, within 10 days of his appointment, the Receiver filed the original

Complaint and Order Appointing the Receiver in 26 United States district courts pursuant to 28

U.S.C. § 754, giving this Court in rem and in personam jurisdiction in each district where the

Complaint and Order have been filed, including the District for the District of Columbia.

10. This Court has personal jurisdiction over the Committee Defendants pursuant to

F.R.C.P. 4(k)(1)(C) and 15 U.S.C. §§ 754 and 1692.

THE PARTIES

11. Plaintiff Ralph S. Janvey, acting in his capacity as Court-appointed Receiver, has

been appointed by this Court as the Receiver for the assets, monies, securities, properties, real

and personal, tangible and intangible, of whatever kind and description, wherever located, and

the legally recognized privileges (with regard to the entities) of Stanford International Bank,

Ltd., Stanford Group Company, Stanford Capital Management, LLC, Robert Allen Stanford,

James M. Davis, Laura Pendergest-Hold, Stanford Financial Group, the Stanford Financial

Group Bldg., Inc., and all entities the foregoing persons and entities own or control (the

“Receivership Assets”).

12. Defendant Democratic Senatorial Campaign Committee, Inc. is a District of

Columbia corporation with its principal office in Washington, D.C.



13. Defendant National Republican Congressional Committee is a political

organization with its principal office in Washington, D.C.

14. Defendant Democratic Congressional Campaign Committee, Inc. is a District of

Columbia corporation with its principal office in Washington, D.C.

15. Defendant Republican National Committee is a political organization with its

principal office in Washington, D.C.

16. Defendant National Republican Senatorial Committee is a political organization

with its principal office in Washington, D.C.

17. Each Defendant will be served pursuant to the Federal Rules of Civil Procedure,

through their attorney of record, or by other means approved by this Court’s order.

STATEMENT OF FACTS

18. On February 16, 2009, the Securities and Exchange Commission commenced a

lawsuit in this Court against R. Allen Stanford, two associates, James M. Davis and Laura

Pendergest-Holt, and three of Mr. Stanford’s companies, Stanford International Bank, Ltd.

(“SIB” or “the Bank”), Stanford Group Company, and Stanford Capital Management, LLC

(collectively “Stanford Defendants”). On the same date, the Court signed an Order appointing a

Receiver, Ralph S. Janvey, over all property, assets, and records of the Stanford Defendants, and

all entities they own or control.

I. Stanford Defendants Operated a Fraudulent Ponzi Scheme

19. As alleged by the SEC, the Stanford Defendants marketed fraudulent SIB CDs to

investors exclusively through SGC Financial Advisors pursuant to a Regulation D private



placement. First Amended Complaint (Doc. 48), ¶ 23.1 The CDs were sold by Stanford

International Bank, Ltd. Id.

20. In marketing, selling, and issuing CDs to investors, the Stanford Defendants

repeatedly touted the CDs’ safety and security and SIB’s consistent, double-digit returns on its

investment portfolio. Id. ¶ 31.

21. In its brochure, SIB told investors, under the heading “Depositor Security,” that

its investment philosophy is “anchored in time-proven conservative criteria, promoting stability

in [the Bank’s] certificate of deposit.” SIB also emphasized that its “prudent approach and

methodology translate into deposit security for our customers.” Id. ¶ 32. Further, SIB stressed

the importance of investing in “marketable” securities, saying that “maintaining the highest

degree of liquidity” was a “protective factor for our depositors.” Id. ¶ 45.

22. In its 2006 and 2007 Annual Reports, SIB told investors that the Bank’s assets

were invested in a “well-balanced global portfolio of marketable financial instruments, namely

U.S. and international securities and fiduciary placements.” Id. ¶ 44. More specifically, SIB

represented that its 2007 portfolio allocation was 58.6% equity, 18.6% fixed income, 7.2%

precious metals and 15.6% alternative investments. Id.

23. Consistent with its Annual Reports and brochures, SIB trained SGC Financial

Advisors, in February 2008, that “liquidity/marketability of SIB’s invested assets” was the “most

important factor to provide security to SIB clients.” Id. ¶ 46. In training materials, the Stanford

Defendants also claimed that SIB had earned consistently high returns on its investment of

deposits (ranging from 11.5% in 2005 to 16.5% in 1993). Id. ¶ 24.

1 Unless otherwise stated, citations to Court records herein are from the case styled SEC v. Stanford Int’l Bank, Ltd., et al., Civil Action No. 3-09-CV-0298-N.



24. Contrary to the Stanford Defendants’ representations regarding the liquidity of its

portfolio, SIB did not invest in a “well-diversified portfolio of highly marketable securities.”

Instead, significant portions of the Bank’s portfolio were misappropriated by the Stanford

Defendants and were either placed in speculative investments (many of them illiquid, such as

private equity deals), diverted to other Stanford Entities “on behalf of shareholder” - i.e., for the

benefit of Allen Stanford, or used to finance Allen Stanford’s lavish lifestyle (e.g., jet planes, a

yacht, other pleasure craft, luxury cars, homes, travel, company credit cards, etc.). In fact, at

year-end 2008, the largest segments of the Bank’s portfolio were: (i) at least $1.6 billion in

undocumented “loans” to Defendant Allen Stanford; (ii) private equity; and (iii) grossly over-

valued real estate. Id. ¶¶ 24, 48.

25. In an effort to conceal their fraud and ensure that investors continued to purchase

the CD, the Stanford Defendants fabricated the performance of SIB’s investment portfolio. Id.

¶ 5.

26. SIB’s financial statements, including its investment income, were fictional. Id.

¶ 37. In calculating SIB’s investment income, Defendants Stanford and Davis provided to SIB’s

internal accountants a pre-determined return on investment for the Bank’s portfolio. Id. Using

this pre-determined number, SIB’s accountants reverse-engineered the Bank’s financial

statements to reflect investment income that SIB did not actually earn. Id.

27. For a time, the Stanford Defendants were able to keep the fraud going by using

funds from current sales of SIB CDs to make interest and redemption payments on pre-existing

CDs. See id. ¶ 1. However, in late 2008 and early 2009, CD redemptions increased to the point

that new CD sales were inadequate to cover redemptions and normal operating expenses. As the

depletion of liquid assets accelerated, this fraudulent Ponzi scheme collapsed.



28. Stanford Defendant Davis has admitted that the Stanford fraud was a Ponzi

scheme from the beginning. See Doc. 771 (Davis Plea Agreement) at ¶ 17(n) (Stanford, Davis,

and other conspirators created a “massive Ponzi scheme”); id. at 41 (“Soon after [Mr. Davis]

became Controller [of Allen Stanford’s Montserrat bank]… in at least 1989… Stanford requested

that, in order to show fictitious quarterly and annual profits, [Mr. Davis] make false entries into

the general ledger for the purpose of reporting false revenues, and false investment portfolio

balances to the banking regulators.”); Doc. 807 (Davis Tr. of Rearraignment) at 19:18-21 (“As

early as 1990, Mr. Davis… at the request of Allen Stanford, began… making false entries into

the books and records of SIBL.”); id. at 16:16-17, 21:6-8, 21:15-17 (admitting the Stanford Ponzi

fraud was a “massive Ponzi scheme ab initio”).

II. Stanford Transferred Funds from the Fraudulent Ponzi Scheme to the Committee Defendants

29. Funds from the Ponzi scheme described above were transferred by Allen Stanford,

James Davis, and Stanford Financial Group to the Committee Defendants. The dates, amounts,

transferors, and transferees of each specific transfer are reflected in Exhibit A.

30. The Committee Defendants received at least the following amounts in total

transfers from Stanford, Davis, and the Stanford Financial Group:

Democratic Senatorial Campaign Committee $950,500

National Republican Congressional Committee $238,500

Democratic Congressional Campaign Committee $200,000

Republican National Committee $128,500

National Republican Senatorial Committee $83,345



31. The Committee Defendants did not furnish any consideration whatsoever in

exchange for the transfers. Thus, the Committee Defendants did not provide reasonably

equivalent value in exchange for these transfers.

32. On or about February 23, 2009, the Receiver made a written demand to the

Committee Defendants for return of the above-referenced payments. After his first demand was

ignored, the Receiver made a second written demand on or about February 9, 2010. Because the

Committee Defendants have ignored the Receiver’s repeated written requests, the Receiver has

been forced to file this lawsuit to carry out his Court-ordered duty to recover monies for the

benefit of the victims of Stanford’s fraudulent scheme.

REQUESTED RELIEF

33. This Court appointed Ralph S. Janvey as Receiver for the “assets, monies,

securities, properties, real and personal, tangible and intangible, of whatever kind and

description, wherever located, and the legally recognized privileges (with regard to the entities),

of the Defendants and all entities they own or control.” Order Appointing Receiver (Doc. 10) at

¶¶ 1-2; Amended Order Appointing Receiver (Doc. 157) at ¶¶ 1-2. The Receiver seeks the relief

described herein in this capacity.

34. Paragraph 4 of the Order Appointing Receiver, signed by the Court on February

16, 2009, authorizes the Receiver “to immediately take and have complete and exclusive control,

possession, and custody of the Receivership Estate and to any assets traceable to assets owned by

the Receivership Estate.” Order Appointing Receiver (Doc. 10) at ¶ 4; Amended Order

Appointing Receiver (Doc. 157) at ¶ 4. Paragraph 5(c) of the Order specifically authorizes the

Receiver to “[i]nstitute such actions or proceedings [in this Court] to impose a constructive trust,

obtain possession, and/or recover judgment with respect to persons or entities who received



assets or records traceable to the Receivership Estate.” Order Appointing Receiver (Doc. 10) at

¶ 5(c); Amended Order Appointing Receiver (Doc. 157) at ¶ 5(c).

35. One of the Receiver’s key duties is to maximize distributions to defrauded

investors and other claimants. See Amended Order Appointing Receiver (Doc. 157) at ¶ 5(g), (j)

(ordering the Receiver to “[p]reserve the Receivership Estate and minimize expenses in

furtherance of maximum and timely disbursement thereof to claimants”); Scholes v. Lehmann, 56

F.3d 750, 755 (7th Cir. 1995) (receiver’s “only object is to maximize the value of the [estate

assets] for the benefit of their investors and any creditors”); SEC v. TLC Invs. & Trade Co., 147

F. Supp. 2d 1031, 1042 (C.D. Cal. 2001); SEC v. Kings Real Estate Inv. Trust, 222 F.R.D. 660,

669 (D. Kan. 2004). But before the Receiver can attempt to make victims whole, he must locate

and take exclusive control and possession of assets of the Estate or assets traceable to the Estate.

Doc. 157 ¶ 5(b).

I. The Receiver is Entitled to Disgorgement of Assets Fraudulently Transferred to the Committee Defendants.

36. The Receiver is entitled to disgorgement of the funds transferred from Stanford,

Davis, and the Stanford Financial Group to the Committee Defendants because such payments

constitute fraudulent transfers under Texas law and other applicable law. See, e.g., TEX. BUS. &

COMM. CODE § 24.005(a). Stanford, Davis, and the Stanford Financial Group made the

payments to the Committee Defendants with actual intent to hinder, delay, or defraud creditors;

as a result, the Receiver is entitled to the disgorgement of those payments.

37. The Receiver may avoid transfers made with the actual intent to hinder, delay, or

defraud creditors. “[T]ransfers made from a Ponzi scheme are presumptively made with intent to

defraud, because a Ponzi scheme is, as a matter of law, insolvent from inception.” Quilling v.

Schonsky, No. 07-10093, 2007 WL 2710703, at *2 (5th Cir. Sept. 18, 2007); see also Warfield v.



Byron, 436 F.3d 551, 558 (5th Cir. 2006) (“. . . [the debtor] was a Ponzi scheme, which is, as a

matter of law, insolvent from its inception. . . . The Receiver’s proof that [the debtor] operated

as a Ponzi scheme established the fraudulent intent behind transfers made by [the debtor].”). The

Stanford Defendants, including Stanford and Davis, and the Stanford Financial Group, were

running a Ponzi scheme and transferred funds generated by that scheme to the Committee

Defendants.

38. Consequently, the burden is on the Committee Defendants to establish an

affirmative defense, if any, of good faith and provision of reasonably equivalent value. See, e.g.,

Scholes, 56 F.3d at 756-57 (“If the plaintiff proves fraudulent intent, the burden is on the

defendant to show that the fraud was harmless because the debtor’s assets were not depleted

even slightly.”). Consideration that has no utility from the creditor’s perspective does not satisfy

the statutory definition of “value.” SEC v. Resources Dev. Intern., LLC, 487 F.3d 295, 301 (5th

Cir. 2007); In re Hinsley, 201 F.3d 638, 644 (5th Cir. 2000).

39. The Committee Defendants cannot meet their burden to establish that they

provided reasonably equivalent value for the payments they received. The Committee

Defendants did not furnish any consideration whatsoever for the above-referenced transfers. To

the extent the Committee Defendants contend that Stanford, Davis, or the Stanford Financial

Group received some sort of intangible non-economic benefit, such benefits do not constitute

reasonably equivalent value in the context of claims for fraudulent transfer. See 1992

Republican Senate-House Dinner Committee v. Carolina's Pride Seafood, Inc., 858 F. Supp.

243, 249 (D.D.C. 1994), vacated after settlement, 158 F.R.D. 223 (D.D.C. 1994) (court refused

to recognize intangible rewards of political contribution as reasonably equivalent value for

fraudulent conveyance purpose); U.S. v. Evans, 513 F. Supp. 2d 825, 835 (W.D. Tex. 2007)



(“The Fifth Circuit has concluded that intangible non-economic benefits do not constitute

reasonably equivalent value for purposes of Texas fraudulent transfer law.”). Accordingly, the

Receiver is entitled to return of the funds transferred, which funds the Committee Defendants

have no legitimate right to retain.

40. The Receiver was only able to discover the fraudulent nature of the above-

referenced transfers after Allen Stanford and his accomplices were removed from control of the

Stanford entities. Thus, the discovery rule and equitable tolling principles apply to any

applicable limitations period. See Wing v. Kendrick, No. 08-CV-01002, 2009 WL 1362383, at

*3 (D. Utah May 14, 2009); Quilling v. Cristell, No. 304CV252, 2006 WL 316981, at *6

(W.D.N.C. Feb. 29, 2006); Warfield v. Carnie, 2007 WL 1112591, at *8 (N.D. Tex. April 13,

2007); see also TEX. BUS. & COMM. CODE § 24.010(a)(1) (claims may be brought either within

four years of the transfer or “within one year after the transfer or obligation was or could

reasonably have been discovered by the claimant”).

41. The Receiver is entitled to recover his costs and reasonable attorneys’ fees

incurred in pursuing these claims. See TEX. BUS. & COMM. CODE § 24.013.

42. The Receiver therefore seeks an order that (a) the payments from Stanford, Davis,

and the Stanford Financial Group to the Committee Defendants constitute fraudulent transfers

under applicable law; (b) the funds transferred from Stanford, Davis, and the Stanford Financial

Group to the Committee Defendants are property of the Receivership Estate held pursuant to a

constructive trust for the benefit of the Receivership Estate; (c) the Committee Defendants are

liable to the Receivership Estate for an amount equaling the amount of funds transferred from

Stanford, Davis, and the Stanford Financial Group to the Committee Defendants; and (d) the



Receiver is entitled to recover his costs and reasonable attorneys’ fees incurred in pursuing these

claims, in addition to pre- and post-judgment interest on any award.

PRAYER

43. The Receiver respectfully requests an Order providing that:

(a) the payments from Stanford, Davis, and the Stanford Financial Group to the

Committee Defendants constitute fraudulent transfers under applicable law;

(b) the funds transferred from Stanford, Davis, and the Stanford Financial Group

to the Committee Defendants are property of the Receivership Estate held

pursuant to a constructive trust for the benefit of the Receivership Estate;

(c) the Committee Defendants are liable to the Receivership Estate for an

amount equaling the amount of funds transferred from Stanford, Davis, and

the Stanford Financial Group to the Committee Defendants; and

(d) the Receiver is entitled to recover his costs and reasonable attorneys’ fees

incurred in pursuing these claims, in addition to pre- and post-judgment

interest on any award and all other relief to which he is justly entitled.



Dated: February 19, 2010 Respectfully submitted,

BAKER BOTTS L.L.P.

By: /s/ Kevin M. SadlerKevin M. SadlerTexas Bar No. [email protected] I. HowellTexas Bar No. [email protected] T. ArlingtonTexas Bar No. [email protected] San Jacinto Center98 San Jacinto Blvd.Austin, Texas 78701-4039(512) 322-2500(512) 322-2501 (Facsimile)

Timothy S. DurstTexas Bar No. [email protected] Ross AvenueDallas, Texas 75201(214) 953-6500(214) 953-6503 (Facsimile)

ATTORNEYS FOR RECEIVER RALPH S. JANVEY



CERTIFICATE OF SERVICE

On February 19, 2010, I electronically submitted the foregoing document with the clerk of the court of the U.S. District Court, Northern District of Texas, using the electronic case filing system of the Court. I hereby certify that I will serve the Democratic Senatorial Campaign Committee (“DSCC”); the National Republican Congressional Committee (“NRCC”); the Democratic Congressional Campaign Committee (“DCCC”); the Republican National Committee (“RNC”); and the National Republican Senatorial Committee (“NRSC”) individually or through their counsel of record, electronically, or by other means authorized by the Court or the Federal Rules of Civil Procedure.

/s/ Kevin M. SadlerKevin M. Sadler


JS 44 (Rev. 12/07) CIVIL COVER SHEETThe JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTION ON THE REVERSE OF THE FORM.)

I.(a) PLAINTIFFSRalph S. Janvey, Receiver

DEFENDANTSDemocratic Senatorial Campaign Committee, Inc.; National Republican Congressional Committee; Democratic Congressional Campaign Committee, Inc.; Republican National Committee; National Republican Senatorial Committee

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF Dallas Co. , Texas(EXCEPT IN U.S. PLAINTIFF CASES)

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT Washignton D.C.(IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)Kevin M. Sadler, Baker Botts L.L.P. 98 San Jacinto Blvd., Ste. 1500

Austin, Texas 78701 Ph: 512.322.2500

ATTORNEYS (IF KNOWN)

II. BASIS OF JURISDICTION (PLACE AN "X" IN ONE BOX ONLY) III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN "X" IN ONE BOX FOR PLAINTIFF (For Diversity Cases Only) AND ONE BOX FOR DEFENDANT)

X 1 U.S. Government Plaintiff

□ 3 Federal Question (U.S. Government Not a Party) Citizen of This State PTF DEF

□ 1 □ 1Incorporated or Principal Place of Business In This State

PTF DEF□ 4 □ 4

Citizen of Another State □ 2 □ 2 Incorporated and Principal Place of Business in Another State

□ 5 □ 5□ 2 U.S. Government Defendant

□ 4 Diversity (Indicate Citizenship of Parties in Item III) Citizen or Subject of a

Foreign Country□ 3 □ 3 Foreign Nation □ 6 □ 6

IV. NATURE OF SUIT (PLACE AN "X" IN ONE BOX ONLY)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

□ 422 Appeal 28 USC 158

□ 423 Withdrawal 28 USC 157

PROPERTY RIGHTS

□ 610 Agriculture□ 620 Other Food & Drug□ 625 Drug Related Seizure of Property 21 USC 881□ 630 Liquor Laws□ 640 R.R. & Truck□ 650 Airline Regs.□ 660 Occupational Safety/Health□ 690 Other

□ 820 Copyrights□ 830 Patent□ 840 Trademark

LABOR SOCIAL SECURITY

□ 110 Insurance □ 120 Marine□ 130 Miller Act□ 140 Negotiable Instrument□ 150 Recovery of Overpayment & Enforcement of Judgment□ 151 Medicare Act□ 152 Recovery of Defaulted Student Loans (Excl. Veterans)□ 153 Recovery of Overpayment of Veteran's Benefits□ 160 Stockholders' Suits□ 190 Other Contract□ 195 Contract Product Liability□ 196 Franchise

PERSONAL INJURY□ 310 Airplane□ 315 Airplane Product Liability□ 320 Assault Libel & Slander□ 330 Federal Employers' Liability □ 340 Marine□ 345 Marine Product Liability□ 350 Motor Vehicle□ 355 Motor Vehicle Product Liability□ 360 Other Personal Injury

PERSONAL INJURY□362 Personal Injury — Med. Malpractice□ 365 Personal injury — Product Liability □ 368 Asbestos Personal Injury Product Liability

PERSONAL PROPERTY□ 370 Other Fraud□ 371 Truth in Lending□ 380 Other Personal Property Damage□ 385 Property Damage Product Liability

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS

□ 861 HIA (1395ff)□ 862 Black Lung (923)□ 863 DIWC/DIWW(405(g))□ 864 SSID Title XVI□ 865 RSI (405(g))

FEDERAL TAX SUITS□ 210 Land Condemnation□ 220 Foreclosure□ 230 Rent Lease & Ejectment□ 240 Torts to Land□ 245 Tort Product Liability□ 290 All Other Real Property

□ 441 Voting□ 442 Employment□ 443 Housing/ Accommodations□ 444 Welfare□ 445 Amer. W/Disabilities - Employment □ 445 Amer. W/Disabilities - Othert □ 440 Other Civil Rights

□ 510 Motions to Vacate SentenceHabeas Corpus:□ 530 General□ 535 Death Penalty□ 540 Mandamus & Other□ 550 Civil Rights

□ 710 Fair labor Standards Act□ 720 Labor/Mgmt. Relations□ 730 Labor Mgmt. Reporting & Disclosure Act□ 740 Railway Labor Act□ 790 Other Labor Litigation□ 791 Empl. Ret. Inc. Security Act

IMMIGRATION□ 462 Naturalization Application□ 463 Habeas Corpus - Alien Detainee□ 465 Other Immigration Actions

□ 870 Taxes (U.S. Plaintiff or Defendant) □ 871 IRS - Third Party

26 USC 7609

□ 400 State Reapportionment□ 410 Antitrust□ 430 Banks and Banking□ 450 Commerce□ 460 Deportation□ 470 Racketeer Influenced and Corrupt Organizations□ 480 Consumer Credit□ 490 Cable/SAT TV □ 810 Selective Service□ 850 Securities/Commodities/ Exchange□ 875 Customer Challenge 12 USC 3410X 890 Other Statutory Actions□ 891 Agricultural Acts□ 892 Economic Stabilization Act□ 893 Environmental Matters□ 894 Energy Allocation Act□ 895 Freedom of Information Act □ 900 Appeal of Fee Determination

Under Equal Access to Justice

□ 950 Constitutionality of State Statutes

V. ORIGIN(PLACE AN "X" IN ONE BOX ONLY)

X 1 Original Proceeding

□ 2 Removed from State Court

□ 3 Remanded from Appellate Court

□ 4 Reinstated or Reopened

□ 5 Transferred from another district (specify)

□ 6 Multidistrict Litigation

□ 7 Appeal to District Judge from Magistrate Judgment

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS

DIVERSITY.) 28 USC 754 & 1692; 15 USC 78aa; 15 USC 77v(a) Brief Description of Cause: Receivership Claims for Disgorgement and Fraudulent Transfer

VII. REQUESTED IN DEMAND $ $1.6 Million CHECK YES only if demanded in complaint: COMPLAINT: CHECK IF THIS IS A CLASS ACTION JURY DEMAND: YES X NO

UNDER F.R.C.P. 23

VIII. RELATED CASE(S) (See Instructions): IF ANY JUDGE Godbey DOCKET NUMBER__3:09cv298-N______________________________

DATE: _____2/19/10______________ _________ SIGNATURE OF ATTORNEY OF RECORD _/s/ Kevin M. Sadler Kevin M. Sadler

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 3:10-cv-00346-F Document 1-2 Filed 02/19/2010 Page 1 of 1

IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

RALPH S. JANVEY, IN HIS CAPACITY AS COURT-APPOINTED RECEIVER FOR THE STANFORD INTERNATIONAL BANK, LTD., ET AL.,

Plaintiff,

v.

DEMOCRATIC SENATORIAL CAMPAIGN COMMITTEE, INC.; NATIONAL REPUBLICAN CONGRESSIONAL COMMITTEE; DEMOCRATIC CONGRESSIONAL CAMPAIGN COMMITTEE, INC.; REPUBLICAN NATIONAL COMMITTEE; and NATIONAL REPUBLICAN SENATORIAL COMMITTEE,

Defendants.

§§§§§§§§§§§§§§§§§§

Case No. 03:10-CV-346

________________________________________________________________________

APPENDIX TO RECEIVER’S ORIGINAL COMPLAINT AGAINST POLITICAL COMMITTEES

________________________________________________________________________


Dated: February 19, 2010 Respectfully submitted,

BAKER BOTTS L.L.P.

By: /s/ Kevin M. SadlerKevin M. SadlerTexas Bar No. [email protected] I. HowellTexas Bar No. [email protected] T. ArlingtonTexas Bar No. [email protected] San Jacinto Center98 San Jacinto Blvd.Austin, Texas 78701-4039(512) 322-2500(512) 322-2501 (Facsimile)

Timothy S. DurstTexas Bar No. [email protected] Ross AvenueDallas, Texas 75201(214) 953-6500(214) 953-6503 (Facsimile)

ATTORNEYS FOR RECEIVER RALPH S. JANVEY


CERTIFICATE OF SERVICE

On February 19, 2010, I electronically submitted the foregoing document with the clerk of the court of the U.S. District Court, Northern District of Texas, using the electronic case filing system of the Court. I hereby certify that I will serve the Democratic Senatorial Campaign Committee (“DSCC”); the National Republican Congressional Committee (“NRCC”); the Democratic Congressional Campaign Committee (“DCCC”); the Republican National Committee (“RNC”); and the National Republican Senatorial Committee (“NRSC”) individually or through their counsel of record, electronically, or by other means authorized by the Court or the Federal Rules of Civil Procedure.

/s/ Kevin M. SadlerKevin M. Sadler


Date Contributor Amount6/22/2000 Stanford Financial Group $15,000.007/17/2000 Stanford, Allen $10,000.007/18/2000 Stanford Financial Group $5,000.009/29/2000 Stanford Financial Group $10,000.00

12/19/2000 Stanford Financial Group $10,000.003/29/2001 Stanford Financial Group $12,500.003/29/2001 Stanford Financial Group $12,500.006/27/2001 Stanford Financial Group $25,000.00

12/28/2001 Stanford Financial Group $50,000.003/14/2002 Stanford Financial Group $100,000.008/9/2002 Stanford Financial Group $500.00

8/15/2002 Stanford Financial Group $100,000.0010/9/2002 Stanford, Allen $250,000.0011/1/2002 Stanford, Allen $250,000.0011/5/2002 Stanford, Allen $50,000.006/30/2003 Stanford, Allen $10,000.006/30/2004 Davis, James $5,000.006/30/2004 Stanford, Allen $10,000.007/20/2005 Stanford, Allen $25,000.00

$950,500.00

Date Contributor Amount4/6/2001 Stanford Financial Group $25,000.00

3/13/2002 Stanford Financial Group $25,000.0010/11/2002 Stanford, Allen $100,000.0011/4/2002 Stanford Financial Group $50,000.009/22/2004 Stanford, Allen $5,000.00

4/8/2005 Stanford, Allen $5,000.005/21/2008 Stanford, Allen $28,500.00

$238,500.00Total Contributions

Donations to Democratic Senatorial Campaign Committee ("DSCC")

Total Contributions

Donations to National Republican Congressional Committee ("NRCC")

1


Date Contributor Amount2/17/2000 Stanford, Allen $20,000.00

8/4/2000 Stanford Financial Group $5,000.003/26/2001 Stanford Financial Group $10,000.005/8/2001 Stanford Financial Group $10,000.00

10/23/2001 Stanford Financial Group $20,000.003/29/2002 Stanford Financial Group $50,000.009/10/2002 Stanford Financial Group $25,000.00

10/21/2002 Stanford Financial Group $50,000.005/31/2003 Stanford, Allen $10,000.00

$200,000.00

Date Contributor Amount6/23/2000 Stanford Financial Group $100,000.007/21/2000 Stanford Financial Group $3,500.00

3/2/2004 Stanford, Allen $25,000.00

$128,500.00

Date Contributor Amount8/28/2000 Stanford Financial Group $20,000.008/30/2000 Stanford Financial Group $20,000.009/12/2000 Stanford Financial Group $250.001/23/2001 Stanford Financial Group $800.00

4/9/2001 Stanford Financial Group $550.006/11/2001 Stanford Financial Group $275.006/21/2001 Stanford Financial Group $20,000.006/25/2001 Stanford Financial Group $20,000.008/16/2001 Stanford Financial Group $400.003/28/2002 Stanford Financial Group $335.004/11/2002 Stanford Financial Group $400.007/10/2002 Stanford Financial Group $335.00

$83,345.00

Donations to National Republican Senatorial Committee ("NRSC")

Total Contributions

Total Contributions

Donations to Republican National Committee ("RNC")

Total Contributions

Donations to Democratic Congressional Campaign Committee ("DCCC")

2


for the northern district of texas dallas division ralph s

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